Contractors ordinarily handle waste determinations and manifests.
The Facility staff signing the manifests are legally responsible
for both waste determinations and accurate reporting on the manifests.

Common violations with respect to the Clean Water Act (CWA) and
the Spill Prevention, Control, and Countermeasure Plan (SPCC):

The Facility lacks a plan. An SPCC plan is required when there
are more than 660 gallons in a single oil tank or there are more
than 1,320 gallons in aggregate above ground or there are more
than 42,000 gallons of oil below ground.

The plan is missing key elements required in the Code of Federal
Regulations Part 112.7.

The plan has not been reviewed every 3 years.

The plan has not been signed and dated by a Certified P.E.

Common violations with respect to Underground Storage Tanks (USTs):

There has been a failure to maintain records of leak detection.

The USTs have not been registered.

Leak detection testing has not been conducted on a UST.

Release detection monitoring has not been conducted.

Common violations with respect to the Clean Air Act (CAA):

Violations of the New Source Performance Standards, including:

Failure to submit proper start-up notifications for boilers.

The particulate standard has been exceeded.

The opacity monitor has been incorrectly calibrated.

There is a failure to submit excess-emission reports.

There has been operation of combustion equipment without valid
permits.

There has been a failure to provide proper notification for
asbestos demolition and renovation activities.

There has been a failure to record the location of asbestos-containing
material on the Facility deed.

Common violations with respect to the Toxic Substances Control
Act (TSCA):

Polychlorinated biphenyl (PCB) record-keeping requirements have
not been met.

PCBs have been used in other than a totally enclosed manner
(e.g. use of a hydraulic fluid containing 110 ppm PCBs to operate
a personnel elevator).

The use of hydraulic fluid containing 250 ppm PCBs.

There have been violations of the one year and the 30 day storage
limits for PCB items.

Common violations of the Safe Drinking Water Act (SDWA) - Underground
Injection Control (UIC):

Unauthorized and unpermitted injection (e.g. operation of wells
without a permit).

Endangerment (e.g. injection of material into wells which may
adversely affect human health).

Common violations of the Clean Water Act (CWA) - National Pollutant
Discharge Elimination System (NPDES):

There has been a failure to obtain a NPDES permit for wastewater
discharges.